Posted By holmezy
Bob,

the CE marking reqts shouldnt apply in this case, in my opinion.

They are much misunderstood reqts anyway....I saw a piece of plywood that had been CE marked the other day!!

Holmezy

Posted By Mike Draper
Oh and with respect to the plywood, that would fall under the Construction Products Directive - 89/106/EEC as amended by 93/68/EEC. For more info, refer to http://www.communities.gov.uk/index.asp?id=1131335

Posted By Simon Carrier
Good morning Bob

I would suggest that Reg10 of Puwer 1998 would be relevant here. In so far as that the item is being made and put into service in house. The product must comply with the essential safety requirements for that product, however if no essential safety requirements available for that product then the requirements of PUWER reg 11-24 must be met. If as you stated you already comply with these regs then I would suggest that your product is ok to use. CE marking, as far as I understand it, is affixed by the producer who has satisfied themselves that their product meets the essential safety requirements for that particular product. If there are no essential safety requirements for a product it necessarily follows that you cannot CE mark it.

Hope this helps

regards

Posted By David A Walker
Bob

You may have to be careful with this. I believe you will need to review various sets of regulations concerning issues with product safety, e.g. Supply of Machinery (Safety) Regs, Simple Pressure Vessels (Safety) Regs, Electrical Equipment (Safety) Regs, etc, to confirm whether CE Marking is required or exemptions exist.

The DTI has on its website (do a search for CE Marking) various FAQ documents for guidance (e.g. file11288.pdf). The DTI guidance states that for machinery, if you are manufacturing equipment for yourself (even if not intending to be sold, but "taking into service"), it is regarded as "self supply" and the Supply of Machinery Regs apply, hence implies CE marking is needed (although this is not explicitly stated as such).

A DTI guidance doc for Electrical Equipment (Safety) Regs states that electrical equipment must satisfy the requirements of the regs, but CE marking is not required for use in your own premises however.

Simple Pressure Vessels permit some exceptions to CE marking for supply and "taking into service".

Complex equipment that consists of being all of those (machine, electrical equipment, simple pressure vessels, etc) I assume default to having to be CE Marked because of the Machinery Regs. A simple and complete overview of guidance from the regulators would be useful IMHO.

This is an interesting question for educational establishments or manufacturers that have R&D departments constructing and supplying themselves with one or low numbers of equipment, or single prototype equipment pending full scale manufacture and supply to others.

What you need to do for CE marking is highly dependent on the type of equipment. Fundamentally its about risk assessment and assessment against essential health and safety requirements (using harmonised or national standards in the absence of harmonised standards). What you do already probably isn't far off the Conformity Assessment process (and final CE marking), if it is applicable to your equipment. You will be carrying out your risk assessments, under PUWER to determine the residual risks after control measures are applied, and you are probably compiling what could constitute a Technical File listing the components, with drawings, designs, calculations carried out, specs, hazard checklists, literature, involvement of third parties, test reports, etc. You perhaps need to appoint a Responsible Person to oversee all this.

To complete the process you may need approval from an Approved Body, prior to CE Marking. That will depend upon the type of equipment and really the associated risks.

The CE Marking process is generally poorly understood and any additional guidance or comments/corrections would be welcome. The HSE have published research reports from surveys that show significant misunderstandings.

Posted By Mike Draper
Nick and Ron

There is no exemption within the Machinery Directive or PUWER which allows a person to manufacture work equipment to which an article 100A directive applies for their own use at work, without consideration of the requirements of the relevant directive.

Placing on the market and putting into service are defined separately and are both encompassed within the definition of "supply". i.e. new equipment that is either placed on the market or put into service must be CE marked.

In this particular case, what is actually being done in practice may meet the requirements of both PUWER and SM(S)R, in which case the only issue is whether or not generating an additional piece of paper would add value.

Mike

Posted By Mike Draper
Ron

Thanks for the reference.

I stand by what I have said though, as the document you have provided is at this moment in time only a draft and I believe my interpretation, based on the directives and the blue guide, is sound in respect of current legal requirements.

That said, I am interested to see how this develops and how providing clearer definitions of simpler concepts will be put in to practice.

I am concerned that an attempt to simplify this issue and potentially exclude self-manufacture for self-use, would simply have the unintended consequence of having manufacturers ceasing to supply complete systems, leaving users with the job of assembly and liability for any failings.

Mike